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    Privacy Policy

    This Privacy Policy details in general terms how we collect, store, use and disclose your personal information under the Australian Privacy Principles.

    TOMRA Collection Pty Ltd., with its registered address in 18 Anella Ave, Castle Hill NSW 2154, Australia, and its group companies (“TOMRA”), collects, stores, and uses your personal information as a data controller in connection with the use of the TOMRA consumer website (the “Sites” or each “Site” including myTOMRA.com.au) and participation in our various reward programs (each a “Program“), accessible via the Site or via any related mobile or computer-based applications (“Apps” including myTOMRA) and other related services (collectively, “Services“) according to this privacy policy (“Privacy Policy”). The Privacy Policy should be read together with and is subject to the Terms of Service.

    For questions and information about Privacy Policy and your rights, please contact us via email at email address:help.tca@tomra.com. For information about our privacy practices related to data from children, please see “Special Note About Children’s Privacy” below.

    All Services are governed by this Privacy Policy and by using or accessing a Service you give consent to the processing, use and disclosure of your data. Please do not install or use the Services if you do not agree to this Privacy Policy.

    TOMRA reserves the right to modify this Privacy Policy. Your continued use of Services will signify your acceptance of the changes to this Privacy Policy. The Privacy Policy as amended from time to time is available in the Site (under “Privacy Policy”) and via the myTOMRA App.

    (You may click on any item below to go directly to that section of this Privacy Policy)

    1. What information does TOMRA collect?
    2. Why does TOMRA collect information about you and how do we use it?
    3. With whom does TOMRA share your information and why?
    4. How can you change your privacy preferences or account information?
    5. What information is collected through integration with social media/third party services?
    6. The Use Of Third Party Ad Serving Technologies
    7. Data processors
    8. Third party links and websites
    9. Information Security
    10. Data Retention
    11. Your rights
    12. Special Notes on Children’s privacy
    13. Updates to the Privacy Policy
    14. Idea Submission
    15. Governing Law
    16. How to Contact Us

    What Information Does TOMRA Collect?

    A. Information You Provide Voluntarily

    In order for you to participate in any TOMRA Service(s), you first must create a TOMRA profile and agree to theTerms of Service on the Site. As a Member, you may provide us with the following types of information, all of which will be subject to this Privacy Policy.

    • Personally identifiable information (“PII“), such as your name, street address, phone number, or email address, which we require to enroll you as a Member and communicate with you.
    • Information about you and your household (such as your age, education, household composition), which we may request to help provide a more personalized experience.
    • Online Profile Information. If you choose to create an online profile on our Site, which is optional, you will have the option to upload certain personal information about yourself that you wish to share through your online TOMRA profile (such as hobbies and interests, pictures, text descriptions, friends, and other profile information similar to other social networking communities). You can update your online profile by logging in to your myTOMRA profile at mytomra.com.au, or in the myTOMRA app, and enter Edit profile under the more menu.

    B. Information Provided About You From Other Sources

    Your participation in some of TOMRA’s Service(s) may lead to us to receive certain additional information about you through third parties. This information may originate from:

    • Customer loyalty programs offered by participating retailers or grocers where you recycle containers as part of a TOMRA Program.
    • Social media and social networking sites like Facebook or Twitter that you have opted to link to your TOMRA online account through the Site. See Social Media/Third Party Services section below for more information about linking to our Site via social media networks.
    • Third party account providers including PayPal to which you transfer payments to in the course of using the Services.

    C. Website Browsing Information:

    When you visit our Site, we track information to assist us administering the Site and analysing Site usage. This information includes:

    • Your Internet Protocol (IP) address
    • The state or country from which you access the Site
    • Date and time of your visit to the Site
    • The kind of browser or computer you use
    • Name of your Internet service provider
    • Web pages from which you link to our Site or go to from our Site
    • The webpages within our Site you view when visiting our Site
    • Geolocation if you access our Site via a mobile device. You will have the option to turn off geolocation on your mobile device, but certain features in our mobile apps may not then work properly for you. As part of website browsing tracking processes described above, we use third-party technology, namely Google Analytics. TOMRA does not knowingly provide Google with any PII as part of using Google Analytics. Further information about the Google Analytics privacy principles can be found at http://www.google.com/intl/en/analytics/learn/privacy.html.

    D. Cookies

    We use cookies to personalize or enhance your user experience and to facilitate the tracking of session and cross session activities. A cookie is a small text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

    One of the primary purposes of cookies is to provide a convenience feature to save you time. For example, if you personalize a web page, or navigate within a site, a cookie helps the site to recall your specific information on subsequent visits. Hence, this simplifies the process of delivering relevant content and eases site navigation by providing and saving your preferences and login information as well as providing personalized functionality.

    The type of information that may be stored in a cookie includes non-PII about you. Some examples may include a randomly assigned user or session identification number, the country where you are located, and your first name to welcome you back to the site. We reserve the right to share aggregated site statistics with third parties, but will not allow other companies to place cookies on our Site unless there is a temporary, overriding customer value (such as merging into our Site another site that relies on third-party cookies).

    You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you reject cookies by changing your browser settings then be aware that this may affect the functionality of our Site.

    The Cookies used in relation to TOMRA’s Services including Sites and Apps are listed here:TOMRA’s Cookies Version 1. Effective date 7 November 2017.

    • Google Analytics

    E. Recycling Patterns

    In order to participate in any of our various recycling and/or reward Programs, TOMRA may record beverage container recycling habits, redemption habits, and other information about you associated with our Programs. For example, we may record the frequency with which you recycle and the weight or volume of the materials you recycle through our Programs as well as the particular containers that your recycle.

    F. When you provide personal information, the information may be sent to servers located in Australia.

    Why Does TOMRA Collect Information About You and How Do We Use It?

    TOMRA uses the information described above to provide you with a superior Member experience and, as necessary, to administer our business through rewards Programs. For example, we collect various types of information that allow us to:

    • Reward Members in our Programs for certain activities including recycling. For example, we may use household recycling data and PII to determine how many Points you have earned in our Programs, or to alert you when you earn Points and to fulfill reward requests.
    • Provide a more personalized online experience by using any images and screen names that you may choose to upload to the Site or select to identify you, both to yourself and to other participants, which may include us publicly displaying on our Site your photo and user name in connection with your profile and activities in our Programs.
    • Verify your identity.
    • Promote partners and vendors who support our various Programs.
    • Conduct research and perform analysis in order to measure, maintain, protect, develop, and improve services to Members.
    • Administer sweepstakes, contests, promotions, or surveys.
    • Communicate with you about special offers, events, new products or services, or surveys.
    • Provide you with information about products and services from us and others, and also to enable trusted marketing partners to communicate with you about their products/services.
    • Serve advertisements to you on the Site which are tailored to your interests based on information we receive about you as set forth above, including tracking your activities while you use our Site. We do not currently use third parties to serve you interest-based advertising, and our Site is not currently coded to respond to “do not track instructions” from web browsers. [NOTE: We understand the TOMRA site will not initially use any third-party tracking services to serve interest-based ads from third parties, but rather TOMRA will do any targeting of ads itself based on the information it receives. If and when the Site starts to use or display ads served from third parties, the privacy policy will need to be updated.]

    With Whom Does TOMRA Share Your Information and Why?

    Except as otherwise described below, TOMRA will not share your PII with others.

    A. With your Consent: We may share or disclose your PII with third parties with your express consent. Should an event arise which we deem appropriate to obtain your express consent, we will contact you directly using the contact information we have on file for you. It is important that you maintain all your information with us current and accurate.

    B. Service Providers: TOMRA, like many businesses, sometimes hires other companies to perform certain business-related functions (e.g. mailing campaigns to customers, maintaining databases, processing payments, and processing purchases). When we employ the services of another company to perform a function of this nature, we will provide them with the information they need to perform their specific function(s) and require them to use it only for the limited purpose of providing the services contracted by TOMRA. In other circumstances, we may use the services of a third party, where both we and the third-party receive your information and the third party also acquires the right to use the information you submit in accordance with its own privacy policy; in such instances, we will provide a link to the third party’s privacy policy to enable you to review the policy before using the particular service. [NOTE: When you use a vendor in the latter category, disclose that fact at the point of data collection and include a link to the vendor’s privacy policy. See part G below on Rewards Partners as an example of this category.]

    C. Participating Retailers. If you elect to participate in a Program offering integration into a participating retailers or grocer loyalty program, information about you and your recycling activities may be shared with the retailer/grocer.

    D. Business Transfers: In the event we sell or transfer our business or assets, including as part of any bankruptcy, our databases may be transferred to the new owner/successor.

    E. Legal Compliance: We may disclose your PII if we are required to comply with a law, regulation or legal request such as a subpoena from a court; to protect the safety of any of our Site users, any person or the general public; to address fraud, security or technical issues; or to protect TOMRA’s rights or property.

    F. Trusted Marketing Partners: From time to time, we may share information about you with trusted third parties for them to market to you goods or services we think may be of interest to you. In order for us to do so, we will ask you for permission. If you wish to opt out from such sharing, you can do so under “Edit profile”.

    G. TOMRA Rewards Program: A key component of our Rewards Programs is the ability for you to earn and redeem reward Points, which are then redeemable for various Rewards offered by our Reward Partners. These Reward Partners are linked to our Rewards Programs both outside and through our Site and integrated into Member Accounts to allow for maximum Member ease in both earning Points and redeeming Rewards with those Points. This integration includes TOMRA making available certain aggregated Member information which is anonymous as to any specific member. In addition, when you claim a Reward from a third-party Reward Partner, you will also be giving information to that Reward Partner which will be subject to that Reward Partner’s privacy policy as well as this privacy policy. We will provide a link to the Reward Partner’s privacy policy at the place where you are submitting your information to such Reward Partner. The TOMRA Rewards Program will commence and apply in the absolute discretion of TOMRA. As at the date of commencement of this Privacy Policy, the TOMRA Rewards Program has not commenced. TOMRA makes no representation that the TOMRA Rewards Program will commence, or will commence in the manner proposed in the Terms of Service.

    H. Non-Personal Aggregate Data: We may provide aggregated anonymous information concerning member usage of our Site to third parties for any purpose not prohibited by law.

    How Can You Change Your Privacy Preferences or Account Information?

    A. To modify your preferences for receipt of marketing messages from TOMRA and/or our continued sharing of information about you with third parties for marketing purposes, you can update your account profile and communication preferences at any time through the Edit profile tools on the Site or by contacting TOMRA’s Customer Care Call Center as indicated below under Contact Us on the “More” page. Promotional emails from TOMRA also will generally include an unsubscribe link to opt-out from future promotional emails from TOMRA.

    B. Even if you opt out of receiving marketing messages, TOMRA will still send specific administrative notices that are required by law, regulation, or as needed to service your Account, including but not limited to notices about your Program activity such as earning of Points and redemption of Rewards.

    C. We encourage you to keep your information with us current and up to date. You can make corrections, updates or deletions to your account information by accessing your online profile and visiting the Edit profile Section of the Site.

    What Information Is Collected Through Integration With Social Media/Third Party Services?

    A. The Site may make access to social media sites available to you. You are not required to provide any personal information when using these areas, but if you do then (i) such information will become publicly available, (ii) you may receive unsolicited messages from other parties with access to the same social media platforms, and (iii) when you post a comment to some social media sites, your user name and possibly your current location may be made publicly available. By accessing social media sites via the Site, you acknowledge that your user name and location information may be disclosed, and that the information you post then becomes subject to the usage terms and privacy policy of the applicable social media site(s); be sure to check those terms and policies.

    B. We may also offer you the ability to sign in to our Site through one or more social networking services. If you do so, any information you supply (or have supplied) to us becomes subject to the privacy policy of that social network/service. We do not control, and are not responsible for, the privacy practices of such networks or services. You should consult the privacy policy of such networks/services.

    C. We cannot ensure the security of any information you choose to make public on social media sites. Also, we cannot ensure that parties who have access to such publicly available information will respect your privacy. Please exercise caution when deciding to disclose personal information in these areas. To request removal of your personal information from any blog or community forum we may offer, contact us at help.tca@tomra.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

    The Use Of Third Party Ad Serving Technologies

    The Site and Apps use third party ad serving technology that use certain methods to collect information as a result of ad serving through Services. Information collected will as a main rule not be personal identifiable.

    TOMRA reserves the right to use and disclose the collected data for purposes of advertising through Services or TOMRA’s partners and contractors.

    Services or third parties operating the ad serving technology may use demographic and geo-location information (for more information regarding use of Location Data see below Section 5) as well as information logged from your hardware or device to ensure that relevant advertising is presented within the Service. TOMRA or third parties may collect and use data, for such purposes, including but not limited to, data such as IP address, email address, Device ID, MAC address, installed software, application usage data, hardware type, Operating System information, browser information, unique identifiers in browser cookies, Flash cookies, and HTML5 local storage, Internet and on-line usage information and in-game information. Please note that you may adjust the settings in your device to accept or not accept cookies. Rejection of cookies may affect functionality in the Services. For further information about cookies, see our Cookies Policy (link) The foregoing data may be used and disclosed in accordance with this Privacy Policy and the privacy policy of the company providing the ad serving technology. TOMRA’s Partners and Contractors are listed here:TOMRA’s Partners and Contractors Version 1. Effective date 7 November 2017.

    • TOMRA Cleanaway Pty Limited
    • PayPal Australia Pty Limited

    Data Processors

    TOMRA uses Data Processors which processes PII on TOMRA’s behalf for the purposes of providing the Services and in accordance with a written data processing agreement.

    For example will TOMRA use your information to perform its own analytics and to enable analytics provided by Google Analytics. We use analytical information for supporting business analysis and operations, business intelligence, product development, improving products and services, personalizing content, providing advertising, and making recommendations. Google Analytics will only receive general web statistics such as browser type, time, language, and which website the user arrived from. TOMRA uses a script which removes the last digits of the user’s IP-address before it is provided to Google Analytics. This information allows Google Analytics to determine your location without receiving any personally identifying information. Information provided to Google Analytics is subject to Google’s Privacy Policy: http://www.google.com/intl/en/policies/privacy/.

    TOMRA uses third party providers who process personal data on TOMRAs behalf for the purposes of providing the Services. They can be found here:TOMRA’s Data Processors Version 1. Effective date 7 November 2017.

    • Chartboost
    • Sentry
    • Cloudinary
    • Twitter
    • Facebook
    • Google
    • Sendgrid
    • Microsoft Azure

    Third Party Links and Websites

    This Privacy Policy applies only to the Site and TOMRA Services. This Site and emails received from TOMRA may contain advertisements for and links to other websites not operated or controlled by TOMRA. The policies and procedures we describe here do not apply to those third party sites. The links to third party websites available on this Site or in any emails sent to you by TOMRA do not imply that TOMRA endorses or has reviewed those third party sites. We suggest contacting those sites directly for information on their privacy policies.

    Information Security

    TOMRA processes personal data in accordance with the Australian Privacy Principles, and follows generally accepted industry standards to maintain appropriate technical and organizational security measures.

    We use reasonable safeguards to help prevent loss, misuse and unauthorized access, disclosure or modification of PII provided to us or collected through the Site. However, because no method of transmitting or storing electronic data on the internet is ever completely secure, we cannot guarantee that such information will never be accessed, used, or released in a manner that is inconsistent with this Privacy Policy.

    Data Retention

    TOMRA retains the collected data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Thereafter TOMRA deletes all aforementioned data in its possession within a reasonable timeframe.

    Please note that some data may be further retained if necessary to resolve disputes, enforce Terms of Service and comply with technical and legal requirements and constraints related to the security, integrity and operation of Services.

    Your rights

    You have the right to review, update or correct your personal data in TOMRA’s possession. You also have the right to withdraw your consent to processing of personal data at all times, and to request that your personal data are being deleted. Note that you can make corrections, updates or deletions to your account information by accessing your online profile and visiting the Edit profile Section of the Site. We may provide you with access unless there is an exception that applies under the Australian Privacy Principles.

    For questions and information about the Privacy Policy and your rights, please contact us via email at help.tca@tomra.com

    TOMRA will need sufficient information from you to establish your identity and to verify your access request, and also to assist us in handling your request.

    Special Note About Children’s Privacy

    This Site is a general audience Site. Our content is neither directed toward minors nor children who are under the age of 13. We do not knowingly collect personal information from children under the age of 13. If TOMRA learns that TOMRA has inadvertently gathered personal data from children under 13 years of age, TOMRA will take reasonable measures to promptly delete such personal data from TOMRA’s records.

    Parents who have questions about personal information that they suspect may have been submitted by a child under the age of 13 should email us at help.tca@tomra.com

    TOMRA requires that companies comply with TOMRA’s Privacy Policy before TOMRA allows those companies to access our sites and Services. However, please note that TOMRA’s partners may have their own policies related to tracking technologies for analytics and ad-serving purposes. TOMRA therefore encourages parents to review the list of Data Processors and the list of Partners and Contractors listed in the section “The Use Of Third Party Ad Serving Technologies” and to become familiar with those parties’ policies and practices.

    Updates to the Privacy Policy

    The Site and our Programs may change from time to time. As a result, it may be necessary for TOMRA to make changes to this Privacy Policy. We reserve the right to update this Privacy Policy at any time, with or without advance notice. In the event there are significant changes in the manner in which we maintain and treat PII or the terms of this Privacy Policy, we will display a notice on our Site. We also may send Members emails to inform them of these changes, though we not obligated to do so. If you object to this Privacy Policy or to any future update of this policy or no longer wish to participate in any TOMRA Reward Programs, you may close your Member Account by contacting us. We encourage you to periodically review this Privacy Policy to stay informed about how we are helping to protect the PII we receive from you. Your continued use of this Site or participation in any of the Programs TOMRA offers after the posting of any change shall constitute your agreement to this Privacy Policy and any of its updates.

    Idea Submissions

    All unsolicited information (other than your PII) that you provide to TOMRA through our Site or through other means (such as by posting to any public areas of the Site or sending us ideas for new services or modifications to our services) is deemed non-confidential and we are free to reproduce, use, disclose, and distribute any of this unsolicited information to others without limitation or attribution.

    Governing Law

    This Privacy Policy is governed by Australian law, including the Privacy Act 1988 (Australia) and the Australian Privacy Principles.

    Contact Us and Complaints

    Should you have any questions or comments or complaint about our Privacy Policy, or regarding how your personal information is collected, stored or used, please contact us at email: help.tca@tomra.com. Postal: TOMRA Collection Pty Ltd, 39 Herbert Street, St Leonards NSW 2064, Australia. We will attempt to respond within a reasonable time. If you are not satisfied with our response, you may also contact the Office of the Australian Information Commissioner.